Some important questions for the Queensland Environment Minister

August 3 1998

------>>>ATTENTION Hon. Rod Welford<<<------

Dear Rod,

Just a quick note to make contact. Congratulations on your dual portfolio.

The following questions I would have normally pursued at the EPCQ, however, I understand, it is no more.

1. Natural Resource Strategy SEQ

As a result of discussions during the drafting of this strategy it has become apparent that the extractives industry is labouring under the impression that inventory or identification of an extractive resources is equal to allocation of that resources. BREC has pointed out in a number of forums that sand and gravel deposits and hard rock reserves also play vital functions in the ecology of SEQ. Such functions as aquifers for base-flows, important habitat for freshwater organisms and the flow of these materials is important in the protection of offshore ecosystems. Does either department have any strategies or policies regarding the environmental allocation of these resources? Currently the RFGM maps indicate that environmentally important areas such as Flinders Peak/White Rock area and both Bribie and Stradbroke Islands are targeted for extractive industries. We believe that we need an extractive EPP as well as review of DNR assessment and allocation of these resources.

2. Delegations for on the spot fines under EPP's

BREC believes that the government should release the review of the three month delegation trial and move towards making this feature a permanent one on our environmental regulatory structure.

3. Ministerial Advisory Committee

BREC believes that the you need the advice, input and support of stakeholders in the restructuring of the DEH and to continue progress in the refinement and development of legislation and policies concerning the environment and natural resources. The previous government tried to implement programs by stealth with little consultation and has left a distasteful legacy of bad policies and legislation. We urge you to establish such committees immediately.

4. Waste EPP and Waste tracking.

When will the results of the public consultation and the new Waste EPP be made available? Also we are interested in the results of the Waste Tracking program and the new disposal facilities. The previous government was opaque in these matters and allowed considerable private sector developments in this area with little or no public scrutiny.

6. Gateway Ports

The gateway ports project was "signed off on" by the previous cabinet. While we accept that employment and wealth creation are important. The public consultation on this project revealed that there was inadequate consideration of environmental matters in this plan including air and water pollution, flooding impacts and the disturbance of acid sulfate soils. These deficiencies will mean that the industrial development will not be either world class or environmental best practice. Are your departments going to correct these deficiencies and review the plans for this project?

7. Brisbane Airport

The BACL is saying that the federal Airports Bill 1996 exempts it from having to address air and water pollution caused by planes and ancillary facilities. Given that this pollution including kerosene and cadmium from the tires will enter sate waters, what arrangements is there between the state government and Air Services Australia to treat and monitor this pollution?

8. Regional Ecosystem protection

Will the DEH act to ensure a) that there is legislative protection for ecosystem both at a state and regional level and b) revise the mapping and assessment of regional ecosystem to reflects their distribution at the province level? The second point alludes the problem of saltmarsh communities that, among others, are listed as being of no concern in the SEQ region which extends to Maryborough , the DEH acknowledges that they are virtually extinct south of Noosa.

9. Environmental Protection Agency

I think it vital for the success of this "new" agency if there is transparency in its formulation and implementation. The experience from other sates has shown that just calling something an Environmental Protection Agency doesn't ensure that the environment is protected. The agency must have the resources and legislative head of powers to carry out its duties. BREC believes that instead of rebadging an existing department the government must ensure that all departments carry out their regulatory functions and are careful, diligent and prudent in their own environmentally relevant activities. To this end, we suggest one reform would be to establish an environmental auditor general with power to audit both regulatory functions and government ERA's. The existing Audit Legislation Amendment Act 1993 provides a workable and easily adapted piece of legislation.

10. ERAs on land development and construction.

The last amendments to the EP Act regulations lists these two ERA's as coming into force, finally, in January 1999. Is the government committed to this timetable and will it set in train a process to work on the implementation of these ERA in a way that involves key stakeholders ?

11. Friendly Societies and the Wallis reforms.

While not directly your portfolio concerns you should be aware that we have been informed by the State Government that as part of Wallis reforms friendly societies will cease to be. The ANA Friendly Society which I am a director of, has been involved in a number of environmental initiatives such as our Ethical Bond, Eco Fund and Business Eco-Fund. We believe that the friendly society tradition is important and cannot be replaced by either a company or association but sits astride these two structures. Friendly Societies lie at the base of cooperatives, credit unions, building societies and trade unions and have had a five hundred year record of providing mutual aid to ordinary people in times of distress. The fact that without any consultation of any sort, we are to abolished and replaced by a dodgy unenforceable company structure is outrageous and we ask you to raise our concerns with your cabinet colleagues.

12. State Environmental Outcomes

What are your departments doing to provide clear guidance to local councils about State desired environmental outcomes with regard to the Integrated Planning Act 1997 ?

13. Classification of ERAs

The last government did a risk assessment and reclassification of ERA's. This risk assessment was flawed and left a number of high risk, such as ports, ERAs as Level 2 Authorities. Is the current government going to revisit this risk assessment and reclassification's ?

No was reply received as at 27th August 1998

ends